Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 1 of 42
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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`ANCORA TECHNOLOGIES, INC.,
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`CIVIL ACTION NO. 6:21-cv-735-ADA
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`Plaintiff,
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`JURY TRIAL DEMANDED
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`vs.
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`GOOGLE LLC,
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`Defendant.
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`DEFENDANT GOOGLE LLC’S ANSWER TO ORIGINAL COMPLAINT
`FOR PATENT INFRINGEMENT
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`Defendant Google LLC (“Google”) hereby submits its Answer in response to Complaint
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`for Patent Infringement filed by Plaintiff Ancora Technologies, Inc. (“Ancora”) as set forth
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`below.
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`Each paragraph of the Answer below corresponds to the corresponding numbered or
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`lettered paragraph of the Complaint. All allegations not expressly admitted herein are denied by
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`Google.
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`RELATED CASE1
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`1.
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`Google admits that the actions Ancora Technologies, Inc. v. Roku, Inc. (W.D.
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`Tex. Jul. 16, 2021); Ancora Technologies Inc. v. Nintendo Co. Ltd. et al. (W.D. Tex. Jul. 16,
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`2021); and Ancora Technologies Inc. v. Vizio, Inc. (W.D. Tex. Jul. 16, 2021) were filed on July
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`16, 2021, in the United States District Court for the Western District of Texas, Waco Division,
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`1 Headings are provided for convenience only and are not admissions.
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`1
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 2 of 42
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`asserting infringement of United States Patent No. 6,411,941. Any remaining allegations in
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`paragraph 1 consist of argument and legal conclusions, to which no response is required, but to
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`the extent a response is required, Google denies the allegations.
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`PARTIES
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`2.
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`Google lacks knowledge or information sufficient to form a belief as to the truth
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`or falsity of the allegations contained in paragraph 2, and therefore denies them.
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`3.
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`Google admits that Google LLC is a Delaware limited liability company with a
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`principal place of business at 1600 Amphitheatre Parkway, Mountain View, California 94043.
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`Google admits that it maintains an office at 500 West 2nd Street, Austin, Texas 78701. Google
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`admits that its registered agent in Texas is Corporation Service Company, 211 East 7th Street,
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`Suite 620, Austin, Texas 78701. Google admits that it is registered to do business in the State of
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`Texas and has been since at least November 17, 2006. Any remaining allegations in paragraph 3
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`consist of argument and legal conclusions, to which no response is required, but to the extent a
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`response is required, Google denies the allegations.
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`JURISDICTION AND VENUE
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`4.
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`Google admits that the Complaint alleges an action arising under the patent laws
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`of the United States, Title 35 of the United States Code. Google admits that this Court has
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`subject matter jurisdiction over actions arising under 28 U.S.C. §§ 1331 and 1338(a). Except as
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`expressly admitted, Google denies any remaining allegations in paragraph 4.
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`5.
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`Google does not contest personal jurisdiction in this District solely for the
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`purposes of this action. Google admits that it has an office at 500 West 2nd Street, Austin, Texas
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`78701. Except as expressly admitted, Google denies any remaining allegations in paragraph 5.
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`2
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`6.
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`Google does not contest personal jurisdiction in this District solely for the
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`purposes of this action. Google denies that it has committed acts of infringement within the
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`Western District of Texas, or any other District. Any remaining allegations in paragraph 6
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`consist of argument and legal conclusions, to which no response is required, but to the extent a
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`response is required, Google denies the allegations.
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`7.
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`Google denies that it has committed acts of infringement within the Western
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`District of Texas, or any other District, and denies any remaining allegations in paragraph 7.
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`8.
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`Google denies that it has committed acts of infringement within the Western
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`District of Texas, or any other District, and denies any remaining allegations in paragraph 8.
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`9.
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`Google admits that venue is proper in this District for purposes of this particular
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`action, but denies that venue is convenient or in the interests of justice under 28 U.S.C. §
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`1404(a). Google admits that it has an office at 500 West 2nd Street, Austin, Texas 78701. Except
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`as expressly admitted, Google denies any remaining allegations in paragraph 9.
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`10.
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`Google admits that venue is proper in this District for purposes of this particular
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`action, but denies that the venue is convenient or in the interests of justice under 28 U.S.C. §
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`1404(a). Google admits that it has an office at 500 West 2nd Street, Austin, Texas 78701. Google
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`denies that it has committed acts of infringement within the Western District of Texas, or any
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`other District, and denies any remaining allegations in paragraph 10.
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`THE ASSERTED PATENT
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`11.
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`Google admits that the title appearing on the face of U.S. Patent No. 6,411,941
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`(the “’941 Patent”) is “Method of Restricting Software Operation Within a License Limitation.”
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`Any remaining allegations in paragraph 11 consist of argument and legal conclusions, to which
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`no response is required, but to the extent a response is required, Google denies the allegations.
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`12.
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`Google admits that the ’941 Patent bears, on its face, an issue date of June 25,
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`2002. Any remaining allegations in paragraph 12 consist of argument and legal conclusions, to
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`which no response is required, but to the extent a response is required, Google denies the
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`allegations.
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`13.
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`Google is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations set forth in paragraph 13 of the Complaint and therefore denies each and
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`every allegation set forth therein.
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`14.
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`Google admits that the ’941 Patent lists, on its face, a named inventor by the name
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`of Miki Mullor. Google is without knowledge or information sufficient to form a belief as to the
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`truth of the remaining allegations set forth in paragraph 14 of the Complaint and therefore denies
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`each and every remaining allegation set forth therein.
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`15.
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`Google admits that an Ex Parte Reexamination Certificate for the ’941 Patent
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`appears, on its face, to have been issued on June 1, 2010. Google is without knowledge or
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`information sufficient to form a belief as to the truth of the remaining allegations set forth in
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`paragraph 15 of the Complaint and therefore denies each and every remaining allegation set forth
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`therein.
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`16.
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`Google is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations set forth in paragraph 16 of the Complaint and therefore denies each and
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`every allegation set forth therein.
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`17.
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`Google admits that certain courts have previously issued orders and opinions
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`regarding the ’941 Patent. Google denies that the ’941 Patent is valid. Any remaining allegations
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`in paragraph 17 consist of argument and legal conclusions, to which no response is required, but
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`to an extent a response is required, Google denies the allegations.
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`4
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`18.
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`Google admits that the United States District Court for the Northern District of
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`California issued a claim construction order in Ancora Techs., Inc. v. Apple Inc., No. 11-CV-
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`06357 YGR, 2012 WL 6738761 (N.D. Cal. Dec. 31, 2012), aff’d in part, rev’d in part, 744 F.3d
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`732 (Fed. Cir. 2014). To the extent that Ancora’s allegations extend beyond the language of the
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`order, Ancora’s allegations consist of argument and legal conclusions to which no response is
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`required, but to the extent a response is required, Google denies the allegations. Google denies
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`any remaining allegations in paragraph 18.
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`19.
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`Google admits that the United States District Court for the Northern District of
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`California issued a claim construction order in Ancora Techs., Inc. v. Apple Inc., No. 11-CV-
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`06357 YGR, 2012 WL 6738761 (N.D. Cal. Dec. 31, 2012), aff’d in part, rev’d in part, 744 F.3d
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`732 (Fed. Cir. 2014). To the extent that Ancora’s allegations extend beyond the language of the
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`order, Ancora’s allegations consist of argument and legal conclusions to which no response is
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`required, but to the extent a response is required, Google denies the allegations. Google denies
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`any remaining allegations in paragraph 19.
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`20.
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`Google admits that the United States Court of Appeals for the Federal Circuit
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`issued an opinion in Ancora Techs., Inc. v. Apple, Inc., 744 F.3d 732 (Fed. Cir. 2014), prior to
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`the Supreme Court’s opinion in Nautilus, Inc. v. Biosig Instruments, Inc., 134 S. Ct. 2120 (2014).
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`To the extent that Ancora’s allegations extend beyond the language of the opinion, Ancora’s
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`allegations consist of argument and legal conclusions to which no response is required, but to the
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`extent a response is required, Google denies the allegations. Google denies any remaining
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`allegations in paragraph 20.
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`21.
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`Google admits that the United States Court of Appeals for the Federal Circuit
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`issued an opinion in Ancora Techs., Inc. v. Apple, Inc., 744 F.3d 732 (Fed. Cir. 2014). To the
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 6 of 42
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`extent that Ancora’s allegations extend beyond the language of the opinion, Ancora’s allegations
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`consist of argument and legal conclusions to which no response is required, but to the extent a
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`response is required, Google denies the allegations. Google denies any remaining allegations in
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`paragraph 21.
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`22.
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`Google admits that the Federal Circuit issued an opinion in Ancora Techs., Inc. v.
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`HTC Am., Inc., 908 F.3d 1343, 1347 (Fed. Cir. 2018), as amended (Nov. 20, 2018). Google
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`denies that the ’941 Patent is valid. To the extent that Ancora’s allegations extend beyond the
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`language of the opinion, Ancora’s allegations consist of argument and legal conclusions to which
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`no response is required, but to the extent a response is required, Google denies the allegations.
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`Google denies any remaining allegations in paragraph 22.
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`23.
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`Google is without knowledge or information sufficient to form a belief as to the
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`truth of the allegations set forth in paragraph 23 of the Complaint and therefore denies each and
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`every allegation set forth therein.
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`24.
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`Google admits that the United States District Court for the Western District of
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`Texas issued a claim construction order in Ancora Techs., Inc. v. LG Elecs., Inc., No. 1:20-cv-
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`00034-ADA (W.D. Tex. June 2, 2020) (Dkt. 69). To the extent that Ancora’s allegations extend
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`beyond the language of the order, Ancora’s allegations consist of argument and legal conclusions
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`to which no response is required, but to the extent a response is required, Google denies the
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`allegations. Google denies any remaining allegations in paragraph 24.
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`25.
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`Google admits that the United States District Court for the Central District of
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`California issued a claim construction order in Ancora Techs., Inc. v. TCT Mobile (US), Inc., No.
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`8:19-cv-02192-GW-AS (C.D. Cal. Nov. 18, 2020) (Dkts. 66 and 69). To the extent that Ancora’s
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`allegations extend beyond the of the order, Ancora’s allegations consist of argument and legal
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`6
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`conclusions to which no response is required, but to the extent a response is required, Google
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`denies the allegations. Google denies any remaining allegations in paragraph 25.
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`COUNT 1 - INFRINGEMENT
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`26.
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`Google repeats and incorporates by reference each preceding paragraph as if fully
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`set forth herein.
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`27.
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`Paragraph 27 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 27, and
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`Google specifically denies that it has committed any acts of infringement.
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`28.
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`Paragraph 28 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 28, and
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`Google specifically denies that it has committed any acts of infringement.
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`29.
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`Paragraph 29 and footnote 1 contains legal conclusions and arguments to which
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`no response is required. To the extent a response is required, Google denies the allegations in
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`paragraph 29 and footnote 1, and Google specifically denies that it has committed any acts of
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`infringement.
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`30.
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`Paragraph 30 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 30,
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`and Google specifically denies that it has committed any acts of infringement
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`31.
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`Google admits that Claim 1 of the ’941 Patent, on its face, recites: “A method of
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`restricting software operation within a license for use with a computer including an erasable,
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`non-volatile memory area of a BIOS of the computer, and a volatile memory area; the method
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`comprising the steps of: [1] selecting a program residing in the volatile memory, [2] using an
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`agent to set up a verification structure in the erasable, non-volatile memory of the BIOS, the
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`verification structure accommodating data that includes at least one license record, [3] verifying
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`the program using at least the verification structure from the erasable non-volatile memory of the
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`BIOS, and [4] acting on the program according to the verification.” To the extent Paragraph 31
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`contains any remaining allegations, Google denies them.
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`32.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://android.googlesource.com/platform/external/avb/+/master/README.md#Build-System-
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`Integration:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://source.android.com/devices/tech/ota:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`8
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 9 of 42
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`the following screenshot is an accurate representation of material located at
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`https://source.android.com/security/verifiedboot:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://source.android.com/devices/tech/ota/nonab:
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 10 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 32, and Google specifically denies that it
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`has committed any acts of infringement.
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`33.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://support.google.com/nexus/answer/6102470?hl=en-
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`GB&ref_topic=3415518#zippy=%2Cnexus-p:
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`10
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 11 of 42
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`[. . .]
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://source.android.com/devices/tech/ota/nonab:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 33, and Google specifically denies that it
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`has committed any acts of infringement.
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`34.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://support.google.com/nexus/answer/7680439?hl=en-GB&ref_topic=3415518:
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`11
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 12 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 34, and Google specifically denies that it
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`has committed any acts of infringement.
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`35.
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`Paragraph 35 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 35, and
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`Google specifically denies that it has committed any acts of infringement.
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`36.
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`Paragraph 36 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 36, and
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`Google specifically denies that it has committed any acts of infringement.
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`12
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`37.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://source.android.com/devices/tech/ota/sign_builds:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 37, and Google specifically denies that it
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`has committed any acts of infringement.
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`38.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://source.android.com/security/verifiedboot/verified-boot:
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`13
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 14 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshots are an accurate representations of material located at
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`https://android.googlesource.com/platform/external/avb/+/master/README.md:
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`[. . .]
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted facts. Ancora’s remaining caallegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 38, and Google specifically denies that it
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`has committed any acts of infringement.
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`39.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://source.android.com/devices/tech/ota/sign_builds:
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`15
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 16 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 39, and Google specifically denies that it
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`has committed any acts of infringement.
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`40.
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`Google denies that as of the date of this Answer, the first screenshot in the
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`allegations of paragraph 40 is an accurate representation of material located at
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`https://source.android.com/devices/bootloader. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://source.android.com/devices/tech/ota/nonab:
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`16
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 17 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 40, and Google specifically denies that it
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`has committed any acts of infringement.
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`41.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at https://source.android.com/devices/tech/ota/nonab:
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`17
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 18 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 41, and Google specifically denies that it
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`has committed any acts of infringement.
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`42.
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`Paragraph 42 contains legal conclusions and arguments to which no response is
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`required. To the extent a response is required, Google denies the allegations in paragraph 42, and
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`Google specifically denies that it has committed any acts of infringement.
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`43.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at https://www.chromium.org/chromium-
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`os/chromiumos-design-docs/verified-boot:
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 19 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://support.google.com/pixelbook/answer/9133875?hl=en:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google denies that as of the date of this Answer,
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`the third screenshot in the allegations of paragraph 43 is an accurate representation of material
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 20 of 42
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`located at https://chromium.googlesource.com/aosp/platform/system/update_engine/#Life-of-an-
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`A_B-Update. Ancora’s remaining allegations contain legal conclusions and arguments to which
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`no response is required. To the extent a response is required, Google denies the allegations in
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`paragraph 43, and Google specifically denies that it has committed any acts of infringement.
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`44.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at:
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`https://support.google.com/pixelbook/answer/7503982?hl=en&ref_topic=7504137:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://support.google.com/pixelbook/answer/7504948?hl=en:
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 21 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
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`https://chromium.googlesource.com/aosp/platform/system/update_engine/#Life-of-an-A_B-
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`Update:
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
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`conclusions and arguments to which no response is required. To the extent a response is
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`required, Google denies the allegations in paragraph 44, and Google specifically denies that it
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`has committed any acts of infringement.
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`45.
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`Google admits that as of the date of this Answer, the following screenshot is an
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`accurate representation of material located at
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`https://support.google.com/pixelbook/answer/9134767?hl=en:
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`21
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 22 of 42
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
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`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
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`the following screenshot is an accurate representation of material located at
`
`https://support.google.com/pixelbook/answer/9133875?hl=en:
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`
`
`
`
`22
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`

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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 23 of 42
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`
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
`
`conclusions and arguments to which no response is required. To the extent a response is
`
`required, Google denies the allegations in paragraph 45, and Google specifically denies that it
`
`has committed any acts of infringement.
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`46.
`
`Paragraph 46 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Google denies the allegations in paragraph 46, and
`
`Google specifically denies that it has committed any acts of infringement.
`
`47.
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`Paragraph 47 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Google denies the allegations in paragraph 47, and
`
`Google specifically denies that it has committed any acts of infringement.
`
`48.
`
`Google denies that as of the date of this Answer, the first screenshot in the
`
`allegations of paragraph 48 is an accurate representation of material located at
`
`https://chromium.googlesource.com/aosp/platform/system/update_engine/#Life-of-an-A_B-
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`Update. Google admits that as of the date of this Answer, the following screenshot is an accurate
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`representation of material located at https://www.chromium.org/chromium-os/chromiumos-
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`design-docs/verified-boot-data-structures:
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`
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`23
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 24 of 42
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`
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
`
`the following screenshot is an accurate representation of material located at
`
`https://www.chromium.org/chromium-os/chromiumos-design-docs/verified-boot-data-structures:
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
`
`the following screenshot is an accurate representation of material located at
`
`https://www.chromium.org/chromium-os/chromiumos-design-docs/verified-boot-data-structures:
`
`
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`24
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 25 of 42
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`
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Google admits that as of the date of this Answer,
`
`the following screenshot is an accurate representation of material located at
`
`http://www.chromium.org/chromium-os/chromiumos-design-docs/verified-boot:
`
`
`
`
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
`
`conclusions and arguments to which no response is required. To the extent a response is
`
`required, Google denies the allegations in paragraph 48, and Google specifically denies that it
`
`has committed any acts of infringement.
`
`49.
`
`Google admits that as of the date of this Answer, the following screenshot is an
`
`accurate representation of material located at
`
`25
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`

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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 26 of 42
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`
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`https://chromium.googlesource.com/chromiumos/third_party/arm-trusted-firmware/+/v1.2-
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`rc0/docs/trusted-board-boot.md:
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
`
`conclusions and arguments to which no response is required. To the extent a response is
`
`required, Google denies the remaining allegations in paragraph 49, and Google specifically
`
`denies that it has committed any acts of infringement.
`
`50.
`
`Google admits that as of the date of this Answer, the following screenshot is an
`
`accurate representation of material located at https://www.chromium.org/chromium-
`
`os/chromiumos-design-docs/firmware-boot-and-recovery:
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`26
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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 27 of 42
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`
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`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
`
`conclusions and arguments to which no response is required. To the extent a response is
`
`required, Google denies the allegations in paragraph 50, and Google specifically denies that it
`
`has committed any acts of infringement.
`
`51.
`
`Google admits that as of the date of this Answer, the following screenshot is an
`
`accurate representation of material located at https://www.chromium.org/chromium-
`
`os/chromiumos-design-docs/verified-boot-data-structures:
`
`27
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`

`

`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 28 of 42
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`
`
`
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Ancora’s remaining allegations contain legal
`
`conclusions and arguments to which no response is required. To the extent a response is
`
`required, Google denies the allegations in paragraph 51, and Google specifically denies that it
`
`has committed any acts of infringement.
`
`28
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`

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`Case 6:21-cv-00735-ADA Document 18 Filed 09/23/21 Page 29 of 42
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`
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`52.
`
`Paragraph 52 contains legal conclusions and arguments to which no response is
`
`required. To the extent a response is required, Google denies the allegations in paragraph 52, and
`
`Google specifically denies that it has committed any acts of infringement.
`
`53.
`
`Google denies that as of the date of this Answer, the first screenshot in the
`
`allegations of paragraph 53 is an accurate representation of material located at
`
`https://support.google.com/chromecast/answer/6292664?hl=en-IN. Google admits that as of the
`
`date of this Answer, the following screenshot is an accurate representation of material located at
`
`https://support.google.com/googlenest/answer/7188572?co=GENIE.Platform%3DAndroid&hl=e
`
`n-AU:
`
`
`
`Google denies any conclusions, characterizations, implications, insinuations or speculations that
`
`Ancora alleges follow from the admitted fact. Google denies that as of the date of this Answer,
`
`the third screenshot in the allegations of paragraph 53 is an accurate representation of material
`
`located at
`
`https://support.google.com/googlenest/answer/9335964?hl=en&co=GENIE.Platform=Android#z
`
`ippy=%2Chow-to-get-software-updates. Google admits that as of the date of this Answer, the
`
`following screenshot is an accurate representation of material located at
`
`https://support.google.co